1.1 We are committed to safeguarding the privacy of Apopcorn website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of Apopcorn visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the publication of your information]. You can access the privacy controls via [http://Apopcorn.com/privacy_policy/].

1.5 In this policy, “we”, “us” and “our” refer to Apopcorn.[ For more information about us, see Section 12.]

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent.

2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you . The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services]. The legal basis for this processing is consent.

2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.8 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.11 We may process identify general category of data. This data may include The service data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of this data is you. This data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose specify personal data category or categories to our suppliers or subcontractors identified below insofar as reasonably necessary for the purposes of offering, marketing and selling relevant goods and/or services to you, We may share your information with a specific organization where you have opted to participate in an offer, competition or service relating to them. They may contact you by email, post, phone or SMS.

We may share your information with carefully selected third parties where they are offering products or services that we believe will interest you. These will only be companies operating in the following sectors:

Retail

Financial Services

Lifestyle

Household & Technology

Public Sector

Claims management companies

Fashion and Leisure Goods

Comparison Websites

Astrology

Electric, Gas, Water & Multi-Utilities

Government

Personal Injury Claims

Food & Drink Producers & Retailers

Debt Collection

Automotive

Home Improvement and Construction

Political

Mis-sold PPI

General Marketing & Advertising

Financial Providers/ Services

Competition Sites

Household Goods & Services

Legal Services

Mis-sold Mortgages

General Retailers

Insurance Providers

Education, Research & Self Improvement

IT Services & Software

Not for Profit

Mis-sold Investments

Shares

Health & Welfare

Media, TV, Radio, Film, Online & Print

Tracing Activities

SERPS/Mis-sold pensions

Parenting

Real Estate

Ascend

Subscription Services

Telecommunications

Personal Injury

Travel and Leisure PursuitsFreebie SitesTracing, ID and FraudThey may contact you by email, post, phone, through on-line advertising or social media. We will only share your mobile telephone number for SMS purposes where you have agreed to specific organizations or sectors contacting you.

We may also share your information with carefully selected third parties for the purposes of Market research and analysis, aggregation, profiling, credit and risk management, revenue collation, database verification and/or to update their records for fraud prevention, debt tracing and anti-money laundering purposes, segmentation and suppression.

3.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 We and our other group companies have offices and facilities in Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection_en.

4.3 The hosting facilities for our website are situated in Dublin24/Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection_en.

4.4 Specify category or categories of subcontractor are situated in Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from HYPERLINK “https://ec.europa.eu/info/law/law-topic/data-protection_en” https://ec.europa.eu/info/law/law-topic/data-protection_en.

4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details will be retained for a minimum period of 1 year follow the sign up date, and for a maximum period of 5 years following sign up date.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) The period of retention of personal data category will be determined based on marketing.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

7. Your rights

7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) The payment of a fee currently fixed at GBP 10; and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified or bank plus an original copy of a utility bill showing your current address).

7.2 We may withhold personal information that you request to the extent permitted by law.

7.3 You may instruct us at any time not to process your personal information for marketing purposes.

7.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b) Status – we use cookies to help us to determine if you are logged into our website;

(c) Personalization – we use cookies to store information about your preferences and to personalize the website for you;

(d) Security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) Advertising – we use cookies to help us to display advertisements that will be relevant to you;

(f) Analysis – we use cookies to help us to analyze the use and performance of our website and services; and

(g) [cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyses the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

10.3 We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: